IMC - Let's Get Active

[Bald Sparrow]

421C. I think the problem with this thread, and others, is that people present facts which are contradicted by others so everyone is confused.

Quote "Pam Campbell of AOPA was in FCL001, the main licensing rulemaking body of EASA. I believe her late husband was one of the father-figures of the IMCr and I think her credentials are impeccable as a "believer" in the IMCr. She did represent the IMCr to EASA. And they rejected it."

So why was FCL.008 set up, as Mike Cross describes, with (as is on the EASA website) the stated ToR's of FCL.008 "to review the IMCr" if the IMCr had been rejected?

I did not mention conspiracy. However, as you have, you say in relation to Jim Thorpe:
"He doesn't "consider" it will be dropped, he has reported the outcome of FCL008 as not having an IMCr."

Yet, as Mike Cross says, the NPA from FCL.008 has not been published.

[421C]

Intersting "analysis". How do you square your assertion that "EASA FCL001 rejected the IMCr." with the TOR for FCL008 which says "However, the groups could not agree on this issue." Who do we believe, you or EASA?

Mike,
My assertation is based on the IMCr not being in the EASA FCL NPA. FCL001 was the Working Group that created that NPA. So it doesn't take any special powers to work out that there was 700pages of stuff they accepted in the NPA (the groups could agree on the issue), and that the IMCr, by not being in it, was rejected (or, if you prefer, "the groups could not agree on this issue").

Bald Sparrow

So why was FCL.008 set up, as Mike Cross describes, with (as is on the EASA website) the stated ToR's of FCL.008 "to review the IMCr" if the IMCr had been rejected?

Perhaps they wanted to consider elements of the IMCr model in their analysis along with reviewing a bunch of other things. Look at an obvious analogy. EASA "rejects" the FAA IR and the basic ICAO minimum training requirements, but it coud surely review both in designing its own qualifications.

I did not mention conspiracy. However, as you have, you say in relation to Jim Thorpe:
"He doesn't "consider" it will be dropped, he has reported the outcome of FCL008 as not having an IMCr."

Yet Mike Cross says the NPA from FCL.008 has not been published.

I believe Jim Thorpe sought permission to update the GA community on the outcome of FCL008 prior to the publication of the final NPA. The working group has had its final meeting, we are told by AOPA. I do not see how the NPA could suddenly have an IMCr pop-up over the next year that the lawyers are finalising bits of it.

brgds
421C

[Bald Sparrow]

Ah. No facts then. My mistake.

But a question. Jim Thorpe's article was entitled along the lines of "a personal perspective". Maybe it's me, but I don't usually seek permission to write my own views. And when was PPL/IR "the GA community"?

I am obviously suffering from PPrunitis and nitpicking other people's posts. As was suggested in the first post of this thread, I will get active by writing to my MP and MEP and leave the forumites to fight over opinions.

[421C]

Ah. No facts then. My mistake.

The fact is that EASA's NPA 2008 17b has 647 pages and the IMCr doesn't appear in them. What fact do you expect? Do you think people publish a list of everything they've rejected?

But a question. Jim Thorpe's article was entitled along the lines of "a personal perspective". Maybe it's me, but I don't usually seek permission to write my own views. And when was PPL/IR "the GA community"?

I am obviously suffering from PPrunitis and nitpicking other people's posts

No, you are just making assumptions and inferences. Mike made the point that the NPA wasn't published. I made the point that JIm had got permission to update the GA community. You made the assumption that this was his article. It wasn't.

[Bald Sparrow]

421C. The conclusion of your argument seems to be that you believe the IMCr was rejected, killed off, by FCL.001 and that is the end of it.

So, to go back to the original subject of this thread, I don’t agree that all hope for the IMCr has been lost so I have registered with EASA to make comments on the NPA from FCL.008 and will also lobby by letter to try to keep the IMCr or even have it adopted EU wide in some form.

[Mike Cross]

The fact is that EASA's NPA 2008 17b has 647 pages and the IMCr doesn't appear in them. What fact do you expect? Do you think people publish a list of everything they've rejected?

Unsurprising that it does not appear as NPA 2008 17b is the output of FCL001 and the IMCR was not in their Tems of Reference

What is surprising is that you continue to think that a lack of reference to something that was not part of their Terms of Reference indicates that they considered and rejected it.

"Would you like a pint?" "Yes please."
"Take note my dear Watson, from his reply I deduce that he considered and rejected the idea of a cheese sandwich. He therefore clearly has an aversion to dairy products."

The IMCR IS in FCL008's Terms of Reference and we'll see an opinion when the NPA is published.

[421C]

421C. The conclusion of your argument seems to be that you believe the IMCr was rejected, killed off, by FCL.001 and that is the end of it.

No, I am saying that I believe the IMCr was presented to FCL001 by Pat Campbell of AOPA and that no-one other than the UK CAA supported it. The reason I believe that is that a senior EASA official told me so in person at a meeting in EASA in Cologne and others have corroborated it. This and various other feedback is why people judge that the IMCr, in whatever guise, is not acceptable as a European qualification. I guess it's why Martin Robinson said AOPA didn't want to try and "foist" the IMCr on Europe.

What is surprising is that you continue to think that a lack of reference to something that was not part of their Terms of Reference indicates that they considered and rejected it.

No, the lack of reference is the obvious factual underpinning. The IMCr could have been attached to the RPPL/LPL. A Mountain Rating was not in the FCL001 ToRs and yet it was included in the NPA.

Mike, your own quote refutes what you are saying and your Sherlock Holmes cheese sandwich "point"

the FCL.001 group and the MDM.032 group (dealing with better regulations for
General Aviation) came to the conclusion that the existing requirements for the Instrument
Rating seemed to be too demanding for the PPL holder. Additionally some of the group
experts were in favor to develop a similar rating as the UK national IMC rating with lesser
requirements than the current requirements for the Instrument Rating (IR) which allows the
pilot to fly in circumstances that require compliance with the Instrument Flight Rules (IFR)
but in certain airspace categories only. However, the groups could not agree on this issue.
Due to the time constraints for the development of the Implementing Rules for licensing it
was agreed to start a separate rulemaking task.

Does this not suggest that FCL001 reviewed the IMCr? Clearly it does. I agree that it also makes it clear that the subject was up for discussion in FCL008. However, that does not change the judgement that EASA were not going to accept the IMCr as a European rating.

My original comment was in a post to Keef and I merely said

1. EASA FCL001 rejected the IMCr. The whole topic of IFR qualifications was referred to FCL008. The GA stakeholders agreed that FCL008 was not going to succeed in an IMCr-like "IR lite", so it focused on the outcomes they judged were the best achievable. The fact that this "best achievable" falls short of what would make you and many others "happy" is regrettable, but unavoidable in the world of GA regulation much of the time

I stand by that. Bald Sparrow and Mike, you are welcome to disagree. I don't have any more "facts" than I have mentioned, I welcome your facts to the contrary. You may prefer other wording to "EASA FCL001 rejected the IMCr. The whole topic of IFR qualifications was referred to FCL008". Fine. I am not going to debate your preference for nuances of expression. Good luck to you if you think the substance of this discussion is anything other than that the IMCr hasn't a hope or prayer as a European qualification. Your debating various terms of reference is going to help the IMCr cause by about the square root of zero. If it makes you feel better, by all means, keep at it.

[Mike Cross]

We'll clearly continue to disagree, so just for fun here's another little bit of pedantry.

There never has been such a thing as a "Mountain Rating"

JAR-FCL defines a "Rating" as

Rating:
An entry in a licence stating special
conditions, privileges or limitations pertaining to
that licence.

In France for example you need either a Qualification Montagne or a log-book sign-off from a mountain qualified instructor to use an altisurface. That ain't a rating within the JAR definition, although it is often incorrectly referred to as such. It's nothing to do with licenses or licensing, it's a local restriction that is lifted for pilots who meet the requirement.

The proposed EASA Mountain Rating is an entirely new qualification that the French may or may not choose to accept in the future as permitting the restriction to be lifted.

From the NPA
"FCL.815 Mountain ratings
(a) Privileges. The privileges of the holder of a wheel mountain rating or a ski mountain rating are to
conduct flights to and from surfaces designated as requiring such a rating by the appropriate
authorities designated by the Member States."

Given that what is to prevent an NPA that says
""FCL.xxx IMC rating
(a) Privileges. The privileges of the holder of an IMC rating are to conduct flights in circumstances that require compliance with the Instrument Flight Rules in national airspace where such a rating may be used as defined by the appropriate authorities designated by the Member States."

That way the UK CAA could designate Class D and downwards and everyone else could do whatever they want - simples!

[Bald Sparrow]

[quote="421C"]

Does this not suggest that FCL001 reviewed the IMCr? Clearly it does. I agree that it also makes it clear that the subject was up for discussion in FCL008. However, that does not change the judgement that EASA were not going to accept the IMCr as a European rating.

[/quote]

The FCL.008 ToR's state "During the transfer of the JAR-FCL requirements into the proposal for EASA Implementing Rules, the FCL.001 group and the MDM.032 group (dealing with better regulations for General Aviation) came to the conclusion that the existing requirements for the Instrument Rating seemed to be too demanding for the PPL holder. Additionally some of the group experts were in favor to develop a similar rating as the UK national IMC rating with lesser requirements than the current requirements for the Instrument Rating (IR) which allows the pilot to fly in circumstances that require compliance with the Instrument Flight Rules (IFR)
but in certain airspace categories only. However, the groups could not agree on this issue. Due to the time constraints for the development of the Implementing Rules for licensing it was agreed to start a separate rulemaking task."

The Objectives go on to say "Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges".

So are you saying that EASA were never going to accept an EU wide IMCr so FCL.008 was a waste of time as the outcome was already decided?

Edited to add--- So by "no-one supported the IMCr", who were the representatives / experts to whom the above refers?

[421C]

So are you saying that EASA were never going to accept an EU wide IMCr so FCL.008 was a waste of time as the outcome was already decided?

No. Again, why do you infer this? Do you think the IMCr is the only conceivable "additional European rating to fly in IMC with less training but also with limited privileges"? FCL008 had other objectives too, regarding the IR and glider flight. It met all of them. It proposed an "additional rating", the EIR. It proposed a more flexible IR and a glider thing I am not familiar with. So how did it fail to meet its ToRs?

[mm_flynn]

So are you saying that EASA were never going to accept an EU wide IMCr so FCL.008 was a waste of time as the outcome was already decided??

FCL.008 was considering three things, rationalising the IR, addressing cloud flying by gliders and considering a rating for limited IFR.

I don't know the answer re gliders. However, FCL.008 clearly did address (and I believe in a very positive way) rationalising the IR requriements, it also addressed the need os a lesser instrument rating - the issue is most IMCr holders seem to believe FCL.008's proposal is wrong, not suffcient, unsafe, chocolate tea pot (select as appropriate). The outcome was not 'already decided' (and I am sure on same Euro ATC forum they are up to page 35 on the problems of anything other than a full IR), IMCr holders just don't like the outcome (and I understand that position).

Edited to add--- So by "no-one supported the IMCr", who were the representatives / experts to whom the above refers?

Everyone on FCL.001 except the UK CAA and Pat Campbell

[Irv Lee]

Well, I was not involved in any of the FCL.001 meetings, but I think those people who were there would tell you:

2007 Sept FCL.001 meeting started to discuss the IMC but the presentation was put off to October - I understand because the UK was last in alphabetical order and the other national ratings (all adopted) were discussed, so there wasn't the time to complete.

2007 Oct FCL.001 meeting had a short paper presented on the IMC. There was no recommendation to adopt it like there was for the other ratings (but then who in their right minds would recommend adoption of such a concept after a paper that took minutes to present?). A paper was also circulated giving proposed 'syllabus' should it be adopted.

I understand the Oct meeting did ask for a 'RIA' (Regulatory Impact for the next meeting in Cologne on 18-20th Dec, after which presumably all the other ratings were included in the FCL consultation and the IMC matter was handed over to FCL.008.

I suspect all the other ratings were easy to pass as they are:

a) easily understood - I think anyone can understand what a mountain rating or an aerobatic rating or a crop spraying rating is after just a 5 minute presentation

b) all the rating except the IMC rating IMPOSED control. i.e. if you didn't adopt an aerobatic rating officially, everyone COULD do aerobatics by default. If you did adopt it, you control who can do aerobatics... If you didn't adopt a mountain rating, everyone COULD operate at mountain fields, if you did adopt it, you control who can use mountain airfields. However, adoption of the IMC rating would have ALLOWED pilots to do something they could not normally do. So it's much easier and 'more in their interest' for EASA to approve any 'control' items without much fuss or time consumed, but there was no way any rating that suddenly allowed something to happen was ever going to be approved.

I can't imagine anyone reading this forum would ever approve an IMC rating when their knowledge on the subject was based on a presentation taking a few minutes. Can you imagine going back to your home authority and reporting you'd approved something like an IMC rating after a few minutes of 'bullets' about it??? The whole FCL.001 process made sure anything like the IMC rating was not approved.

As for 'agitate now' in any way you can by any means - of course you should - no point in waiting for the concrete to be laid and nearly dry, you have to make it awkward for the people thinking about pouring concrete before they mix it.

[mm_flynn]

Mike,

My understanding of the 'Mountain Rating' thing is that EASA has eliminated the ability to have national level signoffs so that French and an Austrian Mountain rating are now valid each country. Any country can train and issue an mountain rating (subject probably to having mountains!). All EASA countries can now designate airports as requiring a mountain rating. Most importantly (with regard to the IMCr), it appears everyone on FCL.001 agreed it was sensible to have an additional rating for altisurfaces (and by implication, the French, etc.) have agreed that it will replace the Qualification Montagne. I certainly was of that view the first time I watched operations at Courchevel!! Clearly everyone on FCL.001 did not share the view the IMCr was a good thing (and Irv's assessment seems quite reasonable as to why this might be true)

It is very important to understand that the UK IMCr doesn't actually make sense in most countries' airspace - you would need to change it to make it Euro wide. I know you can then just fudge it by saying, where local law allows (and that may be the answer) but it is against EASA's stated objectives so it is a political argument to get a policy change to allow national ratings - a very very big ask.

[421C]

As for 'agitate now' in any way you can by any means - of course you should - no point in waiting for the concrete to be laid and nearly dry, you have to make it awkward for the people thinking about pouring concrete before they mix it.

Irv,
The point is what to agitate for? Some of the agitation I believe is both wrong and self-defeating (eg. that FCL008 didn't follow its ToRs, or any expectation that EASA rulemaking is going to add a nationally permitted qualification or a Euro IMCr). Agitate EASA to adopt the FCl008 recommendations, yes. Agitate the CAA/DfT to do what they can for the IMCr in grandfathering/transition, yes. What other agitation do you think will help the IMCr cause? The 'angry militant' claims about the IMCr? Opposing Jim Thorpe's freedom to write a balanced article? Your usual thing about IR holders being rich twits choosing between G&Ts in Geneva vs Cannes?

The IMCr 'campaign' is not short of metaphors. What it is short of is any actual clarity on what it intends to do, specifically, and what expects to achieve, specifically, through such action.

brgds
421C

[Irv Lee]

As for 'agitate now' in any way you can by any means - of course you should - no point in waiting for the concrete to be laid and nearly dry, you have to make it awkward for the people thinking about pouring concrete before they mix it.

Irv,
The point is what to agitate for?

Anything they want to agitate for - or against - however they want to - but not to be swept into the "keep-secrets and wait to see" suffocation.

Your usual thing about IR holders being rich twits choosing between G&Ts in Geneva vs Cannes?

Twits??? Rich yes, why would I think these people are twits?? I do believe that FCL.001 process could never 'pass' the IMC and we never had the politically aware representation to realise and do something about it. As for the 'rich' comment, I do believe FCL.008 set its own 'ground base' to deliberately exclude the possibility of a sensibly enhanced IMC rating, which I know was what (some) senior UK CAA people believed was right. FCL.008 set their own 'rule' from the start for whatever came out of FCL.008 MUST be usable in ALL airspace (inc class A), and in doing so, they were pandering to the 'rich set', (certainly not a 'twit' set!) and ignoring an opportunity to provide real achievable safety stepping stones (plural) up from the bottom for all, so at least hobby pilots could afford to step up someway, and the richer set could progress further.
The current information suggest it's a safety opportunity for all that looks like it been 'avoided' by deliberate manipulation of initial parameters.